Topic · Switzerland
Pillar 3a for U.S. Citizens
A Swiss Pillar 3a is great for Swiss tax — but for a U.S. person an invested 3a usually holds PFICs. Here's the cash-vs-invested split, the provider reality, and what to file.
By Danilson Ramos · Founder, Atamatax
Updated July 2026
Part of the Switzerland hub — every Swiss-US tax topic in one place.
Takes ~2 minutes — then continues into your full free diagnostic.
A Pillar 3a is one of the best Swiss tax tools — but it's also where Americans most often discover a hidden PFIC problem. On Reddit and Swiss-FI forums the recurring line is blunt: the 3a isn't the problem, it's that most hold PFICs within them.
Cash 3a vs invested 3a
- A 3a savings account holds cash — no PFIC, though it's still a reportable foreign account.
- An invested 3a (VIAC, finpension, Frankly) holds non-U.S. funds, which are generally PFICs for a U.S. person — each one its own Form 8621.
Which providers even accept U.S. persons?
This is provider-specific and a moving target. finpension states it cannot offer its investment solution to U.S. persons — registration asks you to confirm you are not a U.S. person. Some U.S. persons report being able to open and invest a VIAC 3a, with the reporting burden on them. Confirm current terms with each provider.
What to file for an invested 3a
- Form 8621 per non-U.S. fund inside the 3a (default §1291 rules).
- FBAR / Form 8938 reporting of the account itself.
- Whether the wrapper raises foreign-trust questions — a debated, fact-specific area.
Not sure if your 3a holds PFICs?
Pick your 3a provider in the free Swiss PFIC checker and see whether your account means Form 8621. Atamatax is tax-preparation software, not a CPA firm, and this is not individualised tax advice.
Authorities cited
- IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
- IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
- IRC §1291 — IRC §1291 — Interest on tax deferral (excess-distribution regime)
- IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
- FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
- IRC §6048 — IRC §6048 — Information reporting for foreign trusts (Forms 3520 / 3520-A)
Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.
Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.